Letter or Testimony

CHA Comments on Medicare Off-campus Provider-based Requirements

CHA submitted comments to the House Committee on Energy & Commerce to provide feedback on changes to Medicare payment policies included in the Bipartisan Budget Act of 2015.

While this legislative provision currently only applies to Medicare reimbursement policy, state Medicaid programs often follow Medicare program rules and definitions. Thus, these changes have the potential to impact children’s hospitals and other providers that provide significant volume of care to Medicaid patients and in underserved communities.

Section 603-type “site-neutral” provisions, if adopted by state Medicaid programs, could result in changes in reimbursement policy that would disincentivize hospitals from expanding or offering new service lines. Many children’s hospitals are already working at capacity. It is critical for children’s hospitals to have the ability to expand to meet patient needs because children’s hospitals have the unique expertise and infrastructure to serve the unique health care needs of children.

Hospital-based outpatient clinics provide services not otherwise available in the community to vulnerable patient populations. However, an expansion of site neutral payment policies could mean that as populations increase and new outpatient services are needed, there will be a significant disadvantage to outpatient facilities opening away from a hospital’s main geographic campus. As a result, those new facilities will not be built in rural or underserved areas, rather, they will be restricted to the main campus of existing hospitals.

Thus, these policies could force migration of outpatient services back to main hospital campuses over time. This is counter to current thinking in modern pediatric clinical care where it has been repeatedly shown that patients are more likely to receive needed care the closer that care is available to their homes. These changes would mean longer travel times for pediatric patients to receive care, which may reduce access to health care services in rural and underserved areas.